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RECEIPT FOR PAYMENT
-------------------
-------------------
Cumberland County Prothonotary's Office
Carlisle, Pa 17013
Receipt Date
Receipt Time
Receipt No,
7/21/2004
14:26:04
153410
LEHMAN JAMES R ET AL (VS) LEHMAN JESSE J ET AL
Case Number 2001-02905
Receipt total. =
.00
TRNS ESC OUT
------------------------ Distribution Of Payment ----------------------------
Transaction Description Payment Amount
MODIFICATION CU 50.00-
REFUND 50.00
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WHITNEY BLAIR MARIE PETTERSON, : IN THE COURT OF COMMON PLEAS OF
Petitioner : CUMBERLAND COUNTY, PENNSYL VANIA
v.
: CIVIL ACTION - LAW
: CUSTODYNISITATION
JAMES R. LEHMAN and
SUEANN LEHMAN and
JESSE J. LEHMAN,
Respondents
: NO. 2001-2905 CIVIL TERM
PRIOR JUDGE: Edgar B. Bayley
ORDER OF COURT
AND NOW,
, 2004, upon consideration of the attached Petition to ModifY Custody,
it is hereby directed that the parties and their respective counsel appear before
, the
conciliator, at
on the _day of
,2004, at
o'clock, _,m"
for a Pre-Hearing Custody Conference. At such conference, an effort will be made to resolve the issues in dispute;
or if this cannot be accomplished, to define and narrow the issues to be heard by the Court, and to enter into a
temporary order. All children age five or older may also be present at the conference, Failure to appear at the
conference may provide grounds for entry of atemporary or permanent order.
FOR THE COURT:
By:
Custody Conciliator
The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with
Disabilities Act of 1990, For information about accessible facilities and reasonable accommodations available to
disabled individuals having business before the court, please contact our office.. All arrangements must be made at
least 72 hours prior to any hearing or business before the court, You must attend the scheduled conference or
hearing.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE, IF YOU DO NOT
HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE
OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP,
CUMBERLAND COUNTY BAR ASSOCIATION
2 LIBERTY AVENUE
CARLISLE, PA 17013
(717) 240-3166
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JAMES R. LEHMAN, and
SUEANN LEHMAN,
Plaintiffs
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYL VANIA
: CIVIL ACTION - LAW
MAY 1 5 ZOOl{P
v,
JESSE J. LEHMAN, and
WHITNEY B, M, PETTERSON,
Defendant
: NO, 01 - ..1 'i6S
CNIL TERM
: IN CUSTODY
ORDER OF COURT
AND NOW, this
day of
, 200 I, upon consideration of the
attached Complaint, it is hereby directed that the parties and their respective counsel appear before
, Esquire, the conciliator, at
, Cumberland County, Pennsylvania, on the
day of
,2001, at
,m" for a Pre-Hearing Custody Conference,
At such conference an effort will be made to resolve the issues in dispute, or if this cannot be
accomplished, to define and narrow the issues to be heard by the Court and to enter into a temporary
Order. All children age five or older may also be present at the conference, Failure to appear at the
conference may provide grounds for entry of a temporary or permanent Order,
BY THE COURT:
By:
Custody Conciliator
The Court of Common Pleas of Cumberland County is required by law to comply with the
Americans with Disabilities Act of 1990, For information about accessible facilities and reasonable
accommodations available to disabled individuals having business before the Court, please contact
our office, All arrangements must be made at least 72 hours prior to any hearing or business before
the Court, You must attend the scheduled conference or hearing,
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT
HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE
SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP,
CUMBERLAND COUNTY BAR ASSOCIATION
2 Liberty Avenue
CARLISLE, PA 17013
(717) 240-3166
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WHI1'NEY BLAffi MARIE PETTERSON, : IN THE COURT OF COMMON PLEAS OF
Petitioner : CUMBERLAND COUNTY, PENNSYLVANIA
v.
: CIVIL ACTION - LAW
: CUSTODYNISI1'ATION
JAMES R. LEHMAN and
SUEANN LEHMAN and
JESSE J. LEHMAN,
Respondents
: NO. 2001-2905 CIVIL TERM
PRIOR JUDGE: Edgar B. Bayley
ORDER OF COURT
AND NOW,
,2003, upon consideration of the attached Petition to ModifY Custody,
it IS hereby directed that the parties and their respective counsel appear before
, the conciliator, at
on the
day of
, 2000, at
o'clock,
.m.,
for a Pre-Hearing Custody Conference. At such conference, an effort will be made to resolve the issues in
dispute; or if this cannot be accomplished, to define and narrow the issues to be heard by the Court, and to enter
into a temporary order, All children age five or older may also be present at the conference. Failure to appear
at the conference may provide grounds for entl)' of a temporal)' or permanent order.
FOR THECOURT:
By:
Custody Conciliator
The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with
Disabilities Act of 1990. For information about accessible facilities and reasonable accommodations available
to disabled individuals having business before the court, please contact our office, All arrangements must be
made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled
conference or hearing,
YOU SHOULD TAKE TillS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT
HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE
OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP,
CUMBERLAND COUNTY BAR ASSOCIATION
2 LIBERTY AVENUE
CARLISLE, P A 17013
(717) 240-3166 I'
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WHITNEY BLAffi MARIE PETTERSON, : IN THE COURT OF COMMON PLEAS OF
Petitioner : CUMBERLAND COUNTY, PENNSYLVANIA
v.
: CIVIL ACTION - LAW
: CUSTODYNISITATION
JAMES R. LEHMAN and
SUEANN LEHMAN and
JESSE J. LEHMAN,
Respondents
: NO. 2001-2905 CIVIL TERM
PRIOR JUDGE: Edgar B. Bayley
PETITION FOR MODIFICATION OF CUSTODY
1. Petitioner, Whitney Blair Marie Petterson, resides at 33 Skyline Drive,
Mechanicsburg, Cumberland County, Pennsylvania 17050,
2. Respondents, James R, Lehman, SueAnn Lehman, and Jesse 1. Lehman reside at 273
Redwood Lane, Carlisle, Cumberland County, Pennsylvania 17013.
3, Petitioner, Whitney Blair Marie Petterson is the natural mother of one (I) child,
namely, Kadin Darius Lehman, born November 28, 1999.
4. Respondents, James R. Lehman and SueAnn Lehman are the paternal grandparents of
one (1) child, namely, Kadin Darius Lehman, born November 28, 1999,
5, Respondent, Jesse 1. Lehman is the natural father of one (I) child, namely, Kadin
Darius Lehman, born November 28,1999,
6. Pursuant to an Order of this Court dated June 20, 2001, a copy of which is hereto
attached as Exhibit A, upon consideration of an agreement of the natural Grandparents, Respondent's
herein, and the natural Father at a Custody Conciliation Conference, it was Ordered that the natural
Grandparents, James R. Lehman and Sueann Lehman, shall have sole legal and primary physical
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custody of the minor child, Kadiin Darious Lehman with the natural mother and/or natural father
having period of partial custody as agreed by the Grandparents and the respective parent.
7, Petitioner had no notice nor did she attend said custody conference referred to in
paragraph 6,
8, Since the issuance of the above referenced Order, substantial circumstances and
facts have changed, giving rise to this Petition,
9, The best interest and welfare of the minor child, will be promoted by a
modification of the present custody agreement.
WHEREFORE, the Petitioner respectfully requests that this Honorable Court modifY the
current custody Order.
PAUL BRAD ORR, ESQUIRE
Attorney for Petitioner
50 East High Street
Carlisle, P A 17013
(717) 258-8558
Supreme Court ID# 71786
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Attorney Verification
I verify that the statements made in the foregoing document are true and correct.
Some of the information may be known to me, but not to my client. I understand
that false statements herein are made subject to the penalties of Pa. c.s. ~ 4904,
relating to unsworn falsification to authorities,
DATE 5 6 OJ 9 J
Paul Bradford Orr, Esquire
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JAMES R. LEHMAN and
SUEANN LEHMAN,
Plaintiffs
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
V.
: NO. 2001-2905 CIVIL TERM
JESSE J. LEHMAN and
WHITNEY B. M. PETTERSON,
Defendants
: CIVIL ACTION - LAW
: IN CUSTODY
ORDER OF COURT
AND NOW, this r'{ day of , 2003, upon
consideration ofthe attached Custody Concilia IOn Report, 't is ordered and directed as
follows:
1, The prior Order of Court dated June 20, 2001 is hereby vacated,
2, The paternal Grandparents, James R. Lehman and Sueann Lehman, shall
have sole legal custody of Kaelin Darius Lehman, born November 28, 1999.
3, The paternal Grandparents shall have primary physical custody ofthe
Child,
4. Father shall have periods of partial physical custody as agreed by the
paternal Grandparents and Father.
5,
follows:
Mother shall have a phased-in period of partial physical custody as
A. Phase I:
1. Beginning Wednesday, June 25, 2003, every Wednesday from 6:00
p,m. to 8 :00 p.m" except for the two week vacation of Grandparents
during the last week of July and the first week of August.
2. Beginning June 28, 2003 one day every weekend, alternating Saturday
and Sunday, from 10:00 a.m. to 6:00 p.m" the additional days are July
6,2003, and July 19, 2003,
3, During Phase I Mother shall spend all designated time with the Child,
4, Conditional upon Mother complying with the Phase I schedule, the
following Phase II schedule shall be implemented. However, in the
event Mother does not comply with the Phase I schedule, partial
physical custody will continue for the same periods of time on
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alternating Saturdays and Sundays as in Phase I until the next
conciliation conference,
B, Phase II
1. Every Wednesday from 6:00 p.m, to 8:00 p,m.
2, Beginning the weekend of August 15-16,2003, alternating weekends
overnight from Friday at 6:00 p,m, to Saturday at 6:00 p,m., the
additional weekends are August 29-30, 2003 and September 12-13,
2003.
6, Mother shall be responsible for all transportation.
7, This Order is entered pursuant to a Custody Conciliation Conference, The
parties may modify the provisions of this Order by mutual consent. In the absence of
mutual consent, the terms of this Order shall control. Another Conciliation Conference is
scheduled for September 18,2003 at 8:30 a.m,
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BY THJ?COURT,
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cc: Paul Bradford Orr, Esquire, for Mother
Jesse Lehman, pro se 7- y- 03
Molly Pitcher Hotel .
13 South Hanover Street (I ~ ~
Carlisle, P A 17013 -- If - ()Jr
Marylou Matas, Esquire, Counsel for p ernal Grandparents
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OF THE F?O-r'-'C')!.IOIAR'f
03 JUL -1 Pi'l 12: 1.4
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JAMES R. LEHMAN and
SUEANN LEHMAN,
Plaintiffs
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
V.
: 2001-2905 CIVIL TERM
JESSE J. LEHMAN and
WHITNEY B. M. PETTERSON,
Defendants
: CIVIL ACTION - LAW
: IN CUSTODY
PRIOR JUDGE: Edgar B. Bayley, J.
CUSTODY CONCILIATION SUMMARY REPORT
IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL
PROCEDURE 1915.3-8, the undersigned Custody Conciliator submits the following
report:
I, The pertinent information concerning the Child who is the subject of this
litigation is as follows:
NAME
DATE OF BIRTH CURRENTLY IN CUSTODY OF
Kadin Darius Lehman
November 28, 1999 Paternal Grandparents
2, A Conciliation Conference was held in this matter on June 24, 2003, with
the following individuals in attendance: the Mother, Whitney B. M, Petterson, with her
counsel, Paul Bradford OIT, Esquire, The Father, Jesse 1. Lehman, pro se, The paternal
Grandparents, James R. Lehman and Sueann Lehman, with their counsel, Marylou Matas,
Esquire,
3. The Honorable Edgar B. Bayley entered an Order of Court dated June 20,
2001 granting sole legal custody to paternal grandparents, primary physical custody to
paternal grandparents with parents having periods of partial physical custody as agreed
by the parties,
4, The parties agreed to the entry of an Order in the form as attached,
fa "',2 'I '-03
Date
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acq line M, Verney, Esquire
Custody Conciliator
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WlllTNEY BLAIR MARIE PETTERSON
PLAINTIFF
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
v.
01-2905 CIVIL ACTION LAW
JAMES R. LEHMAN, SUEANN LEHMAN
AND JESSE J, LEHMAN
DEFENDANT
IN CUSTODY
ORDER OF COURT
AND NOW,
Friday, May 09, 2003
, upon consideration of the attached Complaint,
it is hereby directed that parties and their respective counsel appear before Jacqueline M. Verney, Esq. ,the conciliator,
at 4th Floor, Cumberland County Courthouse, Carlisle on Tuesday, June 03, 2003 at 10:30 AM
for a Pre-Heari~g Custody Conference. At such conference, an effort will be made to resolve the issues in dispute; or
if this cannot be accomplished, to define and narrow the issues to be heard by the court, and to enter into a temporary
order, All children age five or older may also be present at the conference, Failure to appear at the conference may
provide grounds for entry of a temporary or permanent order,
The court hereby directs the parties to furnish any and all existing Protection from Abuse orders,
Special Relief orders, aud Custody orders to the conciliator 48 hours prior to scheduled hearing.
FOR THE COURT.
By: Isl
Jacqueline M. Verney. Esq.
Custody Conciliator
{..
The Court of Common Pleas of Cumberland County is required by law to comply with the
Americans with Disabilitt)S Act of 1990. For information about accessi],le facilities and reasonable
accommodations available to disabled individuals having business before the court, please contact oUr office,
All arrangements must beinade.at least 72 hours prior"to any hearing or business before the court. You must
attend the scheduled conference or hearing.., . ., '
YOU SHOULD TAKE THIS PAPER TO YOUR ATTORNEY AT ONCE. IFYOUDONOT
HAVE AN ATTORNEY OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET
FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP,
Cumberland County Bar Association
32 South Bedford Street
Carlisle, Pennsylvania 17013
Telephone (717) 249-3166
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WIDTNEY BLAIR MARIE PETTERSON, : IN THE COURT OF COMMON PLEAS OF
Petitioner : CUMBERLAND COUNTY, PENNSYLVANIA
v.
: CIVIL ACTION - LAW
: CUSTODYNISITATION
JAMES R. LEHMAN and
SUEANN LEHMAN and
JESSE J. LEHMAN,
Respondents
: NO. 2001-2905 CIVIL TERM
PRIOR JUDGE: Edgar B. Bayley
AFFIDAVIT OF SERVICE
COMMONWEALTH OF PENNSYLVANIA )
COUNTY OF CUMBERLAND
)
AND NOW, this 21" day of May, 2003, I, Paul Bradford Orr, attorney for Whitney Blair
Marie Petterson, Plaintiff, in the above-captioned action, hereby swear that I have served a true copy
of the Custody Complaint, executed by the Plaintiff in the above-captioned matter, upon the Defendant
by depositing the same in the U,S, Mail, postage prepaid, certified, return receipt requested, The
original return receipt card signed by Sue Ann Lehman on May 9, 2003 indicating service was
effected, is marked Exhibit "A", attached hereto and made a part hereof,
Dated: ~ 1:J I /0 '5
PAUL
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Paul Bradford Orr, Esquire
Attorney for Plaintiff
50 East High Street
Carlisle, PA 17013
(717) 258-8558
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. Cdmplete items 1, 2, and 3. Also complete
item 4 jf Restricted Delivery is desired.
. Print your name and address or~1e reverse
so. that we can return the card to ~you.
. Att.ach this card to the back of the mal/piece,
or on the front if space permits.
1. Article Addressed to:
'JA()IlE"S t? Lr;.H (f1t:l"j
5UEANN t....eHmA~
TE:..sSE -;:T. !...u;mA
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2. Article N.umbe:~
/Transfer from service iabel)
PS,J'orm3811, August 2001
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8. Receit by (Pdnted Name)
D. Is delivery address different from item 1?
If YES, enter delivery address below:
3. ServJce Type
t;.!::CertifledMaU
1:J Registered
o Insured Mail
o Express Mail
~eturn Receipt for Merchandise
DC,O.D.
) 4. Restricted Delivery? (Extra Fee)
DYes
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Domestic Return Receipt
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WHITNEY BLAIR MARIE PETTERSON : IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
v.
: CIVIL ACTION - LAW
JAMES R. LEHMAN, SUEANN LEHMAN:
JESSE J. LEHMAN : NO. 01-2905 CIVIL TERM
Defendants : IN CUSTODY
JAMES R. LEHMAN, and
SUEANN LEHMAN,
Plaintiffs
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
: CIVIL ACTION - LAW
v,
JESSE J, LEHMAN, and
WHITNEY B, M. PETTERSON,
Defendants
: NO, 01-2905 CIVIL TERM
: IN CUSTODY
ANSWER TO PETITION FOR MODIFICATION OF CUSTODY
AND NOW, come Respondents, James R, Lehman and SueAnn Lehman, by and through
their attorney of record, Marylou Matas, Esquire, and Answer Petitioner's Petition for
Modification of Custody as follows:
1. Admitted,
2, Admitted in part and denied in part, It is admitted that Respondents, James R.
Lebham and SueAnn Lehman, reside at 273 Redwood Lane, Carlisle, Cumberland
County, Pennsylvania, It is denied that Respondent, Jesse J. Lehman, resides at
that address. By way of further response, Respondents believe that Jesse J.
Lehman resides at 321 Wolf's Bridge Road, Carlisle, Cumberland County,
Pennsylvania.
3, Admitted.
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4, Admitted,
5, Admitted.
6, Admitted,
7, Admitted in part and denied in part, It is admitted that Petitioner did not attend
the custody conciliation conference held on June 13, 2001. It is denied that
Petitioner did not have notice of the custody conciliation conference, By way of
further response, the custody conciliation summary report attached to the Order of
Court dated June 20, 2001, specifically indicates that "Mother, Whitney B, M,
Petterson, was not present although she received notice of the conference," The
aforesaid Order and Report is attached hereto and incorporated herein by
reference as Exhibit "A."
8, Denied, It is denied that since the issuance of the above referenced Order, substantial
circumstances and facts have changed, giving rise to this Petition, By way of further
response, it is averred that substantial circumstances and facts have not changed in
that:
a, Petitioner did not make contact with Respondents herein from January 2002 until
March 2002;
b, Petitioner visited with the child one time in March 2002;
c, Petitioner's mother picked up the child for a visit in April 2002;
d, Petitioner did not make contact with Respondents herein from April 2002 through
October 2002 to request any contact with the child;
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e, Petitioner visited with the child approximately three times in October 2002;
f. Despite making arrangements with Respondents for regular visitation, Petitioner
failed to arrive for scheduled visitation during November 2002;
g, Petitioner visited with the child on December 6, 2002, and did not call the child
again until December 29, 2002;
h, Despite having every opportunity to spend time with the child, Petitioner has only
visited with the child approximately four times since January 2003;
1. Petitioner filed this request for a modification of the custody Order following a
support conference and various support contempt proceedings;
j, During one such recent support proceeding, after requesting that Respondents
herein waive support arrears, Petitioner and/or her parents were heard saying,
"This is bullshit. We're going after the kid,"
k. Respondents believe that Petitioner was taking the child to her then current place
of employment, Hooters, during her limited periods of visitation;
1. Respondents believe that Petitioner is on probation for violations relating to her
failure to pay support;
m, Respondent, Jesse J, Lehman, has frequent contact with the child, visiting him
frequently and calling him daily;
n, Respondents herein continue to provide primary care and affection for the child,
as they have been;
0, It does not appear that Petitioner's circumstances have changed such that a
modification of the Order is warranted,
9. Denied, It is denied that the best interest and permanent welfare of the child will be
promoted by a modification ofthe present custody agreement.
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WHEREFORE, Respondents request that Petitioner's request for a modification of the
current custody Order be denied,
Respectfully submitted,
fI./--.
Marylo s, Esquire
Attorney fi espondents
GRIFFIE & ASSOCIATES
200 North Hanover Street
Carlisle, PA 17013
(717) 243-5551
(800) 347-5552
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VERIFICATION
I verify that the statements made in the foregoing document are true and correct. I
understand that false statements herein are made subject to the penalties of 18 Pa,C,S, Section
4904, relating to unsworn falsifications to authorities.
DATE: ~-j'l-/JJ
~~
SUE ANN uEHMAN
DATE: b- 7-'1-03
~f~
ES R. LEHMAN
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JUN 14 200'ifJJJ .
JAMES R. LEHMAN and
SUEANN LEHMAN,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY,PENNSYL VANIA
v.
: 2001-2905 CIVIL TERM
: CIV'ILkCTION-LAW
JESSE J. LEHMAN and
WHITNEY B. M, PETTERSON,
Defendant
: IN CUSTODY
JESSE J. LEHMAN,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY,PENNSYL VANIA
v.
WHITNEY BLAIR MARIE
PETTERSON,
, Defendant
: NO. 2000-3257 CIVIL TE~
: CIVIL ACTION - LAW ' .
: IN CUSTODY
,
~
. PRIOR JUDGE: Edgar B. Bayley
L
ORDER OF COURT
AND NOW, this JjJ' daYOf~i.J...Je. .,2DOI,uponconsiderationofthe
attached Custody Conciliation Report,' s ordered and directed as follows:
1. The above captioned cases are hereinafter consolidated.
2, The prior Order of Court dated July 25, 2000 is hereby vacated.
3, The Grandparents, James R, Lehman and Sueann Lehman, shall have
sole legal custody of the child, Kadin Darius Lehman, born November 28,1999.
4. The Grandparents shall have primary physical custody of the child with
the ,Mother and/or Father having periods of partial custody as agreed by the Grandparents
and the respective parent.
5. This Order is entered pursuant to an agreement of the Grandparents and
the Father at a Custody Conciliation Conference. The parties may modify the provisions
of this Order by mutual consent. In the absence of mutual consent, the terms of this
Order shall contro1.
Exh..bl+ A
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BY THE COURT,
/SLrJ:;()~1 i313nf(J.
Edg B. Bayley
cc: Marylou Matas, Esquire - Counsel for Grandparents
Jesse J. Lehman, Father, pro se
273 Redwood Lane
Carlisle, PA 17013
Whitney B. M. Petterson, pro se
33 Skyline Drive
Mechanicsburg, P A 17055
ITT~UE_COPY FROM RECORD
n elltlmollY vlh"roo / I here unto set my ~
and t ealof sat1. rt at Carlisle. P8. .' ~i
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JAMES R. LEHMAN and
SUEANN LEHMAN,
Plaintiff
V.
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY,PENNSYLV ANIA
: 2001-2905 CIVIL TERM
: CIVIL ACTION - LAW
JESSE J. LEHMAN and
WHITNEY B. M. PETTERSON,
Defendant
: IN CUSTODY
JESSE J. LEHMAN,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY,PENNSYLV ANIA
V.
WHITNEY BLAIR MARIE
PETTERSON,
Defendant
: NO. 2000-3257 CIVIL TERM
: CIVIL ACTION - LAW
: IN CUSTODY
PRIOR JUDGE: Edgar B. Bayley
CUSTODY CONCILIATION SUMMARY REPORT
IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL
PROCECDURE 1915.3-8, the ni1dersigned Custody Conciliator submits the following
report:
1. The pertinent information concerning the Child who is the subject of this
litigation is as follows:
NAME
DATE OF BIRTH CURRENTLY IN CUSTODY OF
Kadin Darius Lehman
November 28, 1999 " Grandparents and Father
2. A Conciliation Conference was held onJune 13,2001, with the following
individuals in attendance: Grandparents, James R. Lehman and Sueann Lehman,
represented by Marylou Matas, Esquire; Father, Jesse J, Lehman, pro se. Mother,
Whitney B. M, Petterson, was not present although she received notice of the conference.
No counsel appeared for Mother.
3. A prior Order dated July 25, 2000 was in effect captioned and docketed as
Jesse 1. Lehman v, Whitnev Blair Marie Petterson at No, 2000-3257, The Order of July
25,2000 provided for the parents to have shared legal and physical custody of the child:.
Mother has had little contact with the child and Father, although living with the
Grandparents and the child, has not assumed a parenting role.
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4. The Grandparents and Father agreed to the vacation of the prior Order of
July 25, 2000, consolidation of the two cases and entry of an Order in the form attached,
Irlt./-o /
Date
9n.~
cq me M. Verney, Esquire
Custody Conciliator
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JAMES R. LEHMAN, and
SUEANN LEHMAN,
Plaintiffs
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
: CIVIL ACTION - LAW
v.
JESSE J. LEHMAN, and
wmTNEY B. M, PETTERSON,
Defendant
~ NO, OJ... ;;;Lt;orl
CIVIL TERM
: IN CUSTODY
COMPLAINT FOR CUSTODY
1. Plaintiffs are James R. Lehman and SueAnn Lehman, adult individuals currently
residing at 273 Redwood Lane, Carlisle, Cumberland County, Pennsylvania.
2, Defendant Jesse J, Lehman is an adult individual currently residing at 273 Redwood
Lane, Carlisle, Cumberland County, Pennsylvania
3, Defendant Whitney B. M, Petterson is an adult individual currently residing 33
Skyline Drive, Mechanicsburg, Cumberland County, Pennsylvania,
4, Defendants are the natural parents of one (1) child, namely, Kadin Darius Lehman,
born November 28,1999,
The child was born out of wedlock.
5, Plaintiffs are the paternal grandparents of the child at issue.
6, For the past five (5) years, or since the child's birth, the child has resided with the
following persons at the following addresses for the following periods oftime:
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NAME
James R. Lehman
SueAnn Lehman
Jesse 1. Lehman
Whitney B, M. Petterson
Whitney B. M, Petterson
Whitney B. Petterson
Elaine Petterson
James R. Lehman
SueAnn Lehman
Jesse 1. Lehman
James R. Lehman
SueAnn Lehman
Jesse 1. Lehman
Whitney B, M, Petterson
James R. Lehman
SueAnn Lehman
Jesse 1. Lehman
James R. Lehman
SueAnn Lehman
Jesse 1. Lehman
Whitney B. M. Lehman
James R. Lehman
SueAnn Lehman
Jesse J. Lehman
James R, Lehman
SueAnn Lehman
James R. Lehman
SueAnn Lehman
Jesse 1. Lehman
ADDRESS
DATES
273 Redwood Lane
Carlisle, P A
birth to
February 22, 2000
33 Skyline Drive
Mechanicsburg, P A
February 22, 2000 to
February 27,2000
273 Redwood Lane
Carlisle, P A
February 27, 2000 to
April 2000
273 Redwood Lane
Carlisle, P A
April 2000 to
May 2000
'273 Redwood Lane
Carlisle, P A
May 2000 to
July 2000
273 Redwood Lane
Carlisle, P A
July 2000 to
October 2, 2000
273 Redwood Lane
Carlisle, P A
October 2, 2000
March 23, 2001
273 Redwood Lane
Carlisle, P A
March 23, 2001 to
April 9, 2001
273 Redwood Lane
Carlisle,.PA
April 9, 2001 to
Present
The natural mother of the child is Whitney B, M, Petterson who resides as
aforesaid, She is single,
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The natural father of the child is Jesse J, Lehman who resides as aforesaid. He is
single,
5, The relationship of the Plaintiffs to the child is that of paternal grandparents, The
Plaintiffs currently resides with the child at issue and with the natural father,
6, The relationship of Defendant Jesse J. Lehman to the child is that of natural father
(hereinafter referred to as "Father"). Father currently resides with the child at issue
and with the Plaintiffs,
7, The relationship of Defendant Whitney B, M, Petterson is that of natural
mother(hereinafter referred to as "Mother"), Mother currently resides with the
maternal grandparents, Whitney B, and Elaine Petterson, and her brother, Brandon
Petterson.
8, Mother and Father are subject to an Order of Court dated July 25, 2000, which is
attached hereto and incorporated herein by reference as Exhibit "A" relating to
custody of the child at issue,
9. Plaintiffs have not participated as a party or witness, or in any other capacity in other
litigation, concerning custody of the child,
10. Plaintiffs have no information of any custody proceedings concerning the child
pending in any Court of this Commonwealth.
11. It is in the best interest and permanent welfare of the child to grant the relief
requested because:
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a) Plaintiffs have been and continue to be the primary custodian for the child at issue
from the time of his birth through present;
b) Plaintiffs have been and continue to be in loco parentis with respect to the child at
issue;
c) Mother and Father have shown an inability to provide for the financial, physical,
or emotional needs of the child;
d) Despite being subject to an Order of Court dated July 25, 2000, regarding custody
of their child, Mother and Father have never followed any of the provisions of the
Order;
e.) Father has demonstrated parental unfitness and a lack of interest in the child
through his limited contact, absence of affection, and inappropriate attempts to
discipline the child;
f.) Although Father resides with the child at issue, Father does not interact with the
child, is very seldom alone with the child and is not responsible for the
supervisions or care of his child,
g,) Mother has indicated to Plaintiffs that she will agree to this request by Plaintiffs
to have primary physical custody of the child;
12, Plaintiffs do not know any person not a party to these proceedings who claims to
have custody or visitation rights with respect to the child.
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WHEREFORE, Plaintiffs requests your Honorable Court to schedule Custody
Conciliation Conference followed by a hearing at which time they should be granted primary
physical and legal custody of the child,
Respectfully submitted,
/1';. .
Marylo
Attorney Plaintiff
GRIFFIE & ASSOCIATES
200 North Hanover Street
Carlisle, P A 17013
(717) 243-5551
(800) 347-5552
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VERIFICATION
We verify that the statements made in the foregoing document are true and correct. We
understand that false statements herein are made subject to the penalties of 18 Pa.C,S, Section
4904, relating to unsworn falsifications to authorities,
DATE:) -'i[-ol
11
DATE: .j':P-O I
~.Un~
SUEANN LE
, Plaintiff
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:
JESSE J. LEHMAN I
Plaintiff
: IN THE 0)tJRT OF COMMON PLEAS OF
: CUMBERLAND CCXlNTY, PENNSYLVANIA
:
vs.
: NO, 00-3257
CIVIL TERM
,
.
WHITNEY BLAIR MARIE PETl'ERSEN I
Defendant
: CIVIL ACrION - LAW
:
,
,
CUSTODY
ClIDER OF <XXlRT
AND R:W, this 23
upon consideration of the attached
ordered and directed as follows:
day of
CUstody
ConcJ~~ Report,l ;tO~~
1. The Father, Jesse J. Lehman, and the Motherl Whitney Blair Marie
Pettersen I shall have shared legal custody of Kadin Darius Lehman, bom
November 281 1999. Each parent shall have an equal right, to be exercised
jointly with the other parenti to make all major non-emergency decisions
affecting the Child's general well-being including, but not limited to, all
decisions regarding his health1 education, and religion.
2. '1he parties shall have physical custody of the Child in accordance
with the following schedule:
A. The Mother shall have custody of the Child every week from
7:00 a.m. until 3:00 p.m. on Tuesday through Friday and from
Saturday at 7:00 a.m. through Sunday at 7:00 p.m.
B. The Father shall have custody of the Child at all other times
not specified for the Mother.
3. The parties shall share or altemate having custody of the Child
on holidays as follows;
A. CBRIS'DlAS: The Christmas holiday shall be divided into
Segment Al which shall run frcm Christmas Eve at 12:00 noon
through Christmas Day at 12:00 noon, and Segment Bl which
shall run frcm Christmas Day at 12:00 noon through December 26
at 12:00 noon. The Father shall have custody of the Child
during Segment A in even numbered years and during Segment B
in odd numbered years. The Mother shall have custody of the
Child during Segment A in odd numbered years and during
Segment B in even numbered years,
B. ElISl.'ER: In every year I the Mother shall have custody of the
Child on Easter until 12:00 noon and the Father shall have
custody from 12:00 noon until the beginning of the Mother's
next period of custody under the regular schedule.
f){tfIBIT "AU
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C. MCf.rBER'S DAY/FATHER'S DAY: The Father shall have custody of
the Child every year on Father's Day frOlll 12:00 noon through
the begiMing of the Mother's next period of custody under the
regular sohedule. The Mother shall have custody of the Child
on Mother's Day in accordance with the regular custody
sohedule.
D. The holiday custody sohedule shall supet:sede and _take
precedence over the regular sohedu1e,
4. Eaoh party shall be entitled to have custody of the Child for two
weeks eaoh summer (to be soheduled non-consecutively unless otherwise
agreed) upon providing at least 60 days advance notice to the other party.
5. The party relinquishing custody shall be responsible to provide
transportation for the exchange of custody unless otherwise agreed between
the parties,
6. This Order is entered pursuant to an agreement of the parties at a
CUstody Conciliation Conference. The parties may modify the provisions of
this Order by mutual consent. In the absence of mutual consent1 the terms
of this Order shall control,
BY THE a:JURT I
cc: Thomas S. Diehl, Esquire - Counsel for Father
Maryann Murphy, Esquire - Counsel for Mother
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JESSE J. LEHMAN I
plaintiff
: IN TIlE mORT OF COMMON PLEAS OF
: CUMBERLAND C<XlNTY I PENNSYLVANIA
:
vs,
: NO, 00-3257
CIVIL TERM
:
WHITNEY BLAIR MARIE PE'lTERSEN,
Defendant
: CIVIL ACrION - LAW
:
: CUSTODY
CUS.LW%' <nlCILIATION SUMMARY REPCRl'
IN AccamANCE W1TfI ClJmERLAN[) CCXJNTY RIlLE OF CIVIL Pr<u..:wt.n<E
1915.3-81 the undersigned CUstody Conciliator submits the following report:
1. '!'he pertinent infornation concerning the Child who is the subject
of this litigation is as follows:
ClJRRENTLY IN UJ::;".LWX OF
NAME
DM'E OF BIRrH
Kadin Darius Lehman
November 281 1999
Mother/Father
2. A Conciliation Conference was held on July 191 20001 with the
fOllowing individuals in attendance: The Father, Jesse J. Lehman, with his
oounse11 1'homas S. Diehl, Esquire, and the Mother I Whitney Blair Marie
Pettersen, with her counsell Maryann MurphYl Esquire.
3, The parties agreed to entry of an Order in the form as attached.
Date ~
t?, :J-ot7V
,
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CUstody Conciliator
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JAMES R. LEHMAN AND SUEANN LEHMAN
PLAINTIFF
V.
JESSE J. LEHMAN AND WHITNEY B.M.
PETTERSON
DEFENDANT
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
01-2905 CIVIL ACTION LAW
IN CUSTODY
ORDER OF COURT
AND NOW, Friday, May 18, 2001 , upon consideration of the attached Complaint,
it is hereby directed that parties and their respective counsel appear before Jacqueline M. Verney, Esq. , the conciliator,
at 4th Floor, Cumberland Connty Courthouse, Carlisle on Wednesday, June 13, 2001 at 10:30 a.m.
for a Pre-Hearing Custody Conference. At such conference, an effort will be made to resolve the issues in dispute; or
if this cannot be accomplished, to define and narrow the issues to be heard by the court, and to enter into a temporary
order. All children age five or older may also be present at the conference, Failure to appear at the conference may
provide grounds for entry of a temporary or permanent order.
The conrt hereby directs the parties to furnish any aud all existing Protection from Abuse orders,
Special Relief orders, and Custody orders to the conciliator 48 hours prior to scheduled hearing.
FOR THE COURT,
By: /s/
Jacqueline M. Vernry. Esq. t2P
Custody Conciliator
The Court of Common Pleas of Cumberland County is required by law to comply with the
Americans ffith Disabilites Act of 1990. For information about accessible facilities and reasonable
accommodations available to disabled individuals having business before the court, please contact our office.
All arrangements must be made at least 72 hours prior to any hearing or business before the court. You must
attend the scheduled conference or hearing,
YOU SHOULD TAKE THIS PAPER TO YOUR ATTORNEY AT ONCE. IF YOU DO NOT
HA VB AN ATTORNEY OR CANNOT AFFORD ONE, GO TO OR TELEPHONE TIIE OFFICE SET
FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP,
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, Pennsylvania 17013
Telephone (717) 249-3166
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JAMES R. LEHMAN and
SUEANN LEHMAN,
Plaintiffs
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
v,
CIVIL ACTION - LAW
JESSE J. LEHMAN and
WHITNEY B, M. PETTERSON,
Defendant
: NO. 01-2905 CIVIL TERM
: IN CUSTODY
AFFIDAVIT OF SERVICE
AND NOW, this 6111 day of June, 2001, comes Marylou Matas, Esquire, Attorney for
Plaintiffs, and states that a true and attested copy of a Complaint for Custody and related Order
of Court dated May 18, 2001, was sent to Defendant Jesse J, Lehman of 273 Redwood Lane,
Carlisle, P A 17013 by certified mail, restricted delivery, return receipt requested, A copy of said
receipt is attached hereto indicating that service was made on May 26, 200 I,
ifY\...-
Marylou a as, Esqu
Attorney 0 laintiffs
GRIFFIE & ASSOCIATES
200 North Hanover Street
Carlisle, P A 17013
(717) 243-5551
(800) 347-5552
Sworn and subscribed to
before m this ({flit day
of ,2001
, Nolarlal Seal
Ka~sa J, Lehman. NI?farlI Public
Canlsle Bora, CuIribeIlarKt <;ounty
My Commission Expll'9$ Aug. 25, 2003
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JAMES R. LEHMAN and
SUEANN LEHMAN,
Plaintiff
v.
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY,PENNSYLVANIA
: 2001-2905 CIVIL TERM
CIVIL ACTION - LAW
JESSE J. LEHMAN and
WHITNEY B. M. PETTERSON,
Defendant
IN CUSTODY
JESSE J. LEHMAN,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY,PENNSYLV ANIA
v,
WHITNEY BLAIR MARIE
PETTERSON,
Defendant
NO. 2000-3257 CIVIL TERM
CIVIL ACTION - LAW
: IN CUSTODY
PRIOR JUDGE: Edgar B. Bayley
ORDER OF COURT
AND NOW, this ~ day of ~~upon consideration of the
attached Custody Conciliation Report, it is ordered and directed as follows:
I, The above captioned cases are hereinafter consolidated,
2, The prior Order of Court dated July 25, 2000 is hereby vacated,
3, The Grandparents, James R. Lehman and Sueann Lehman, shall have
sole legal custody of the child, Kadin Darius Lehman, born November 28,1999,
4. The Grandparents shall have primary physical custody ofthe child with
the Mother and/or Father having periods of partial custody as agreed by the Grandparents
and the respective parent.
5, This Order is entered pursuant to an agreement of the Grandparents and
the Father at a Custody Conciliation Conference. The parties may modify the provisions
of this Order by mutual consent, In the absence of mutual consent, the terms of this
Order shall control.
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cc: Marylou Matas, Esquire - Counsel for Grandparents
Jesse J, Lehman, Father, pro se
273 Redwood Lane
Carlisle, P A 17013
Whitney B. M, Petterson, pro se
33 Skyline Drive
Mechanicsburg, P A 17055
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Plaintiff
V.
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY,PENNSYLV ANIA
: 2001-2905 CIVIL TERM
: CIVIL ACTION - LAW
JESSE J. LEHMAN and
WHITNEY B. M. PETTERSON,
Defendant
: IN CUSTODY
JESSE J. LEHMAN,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY,PENNSYLV ANIA
V,
WHITNEY BLAIR MARIE
PETTERSON,
Defendant
: NO. 2000-3257 CIVIL TERM
: CIVIL ACTION - LAW
: IN CUSTODY
PRIOR JUDGE: Edgar B. Bayley
CUSTODY CONCILIATION SUMMARY REPORT
IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL
PROCECDURE 1915.3-8, the undersigned Custody Conciliator submits the following
report:
1. The pertinent information concerning the Child who is the subject ofthis
litigation is as follows:
NAME
DATE OF BIRTH CURRENTLY IN CUSTODY OF
Kadin Darius Lehman
November 28, 1999 Grandparents and Father
2, A Conciliation Conference was held on June 13,2001, with the following
individuals in attendance: Grandparents, James R. Lehman and Sueann Lehman,
represented by Marylou Matas, Esquire; Father, Jesse J, Lehman, pro se. Mother,
Whitney B, M, Petterson, was not present although she received notice of the conference,
No counsel appeared for Mother,
3, A prior Order dated July 25,2000 was in effect captioned and docketed as
Jesse 1. Lehman v, Whitnev Blair Marie Petterson at No, 2000-3257, The Order of July
25,2000 provided for the parents to have shared legal and physical custody of the child,
Mother has had little contact with the child and Father, although living with the
Grandparents and the child, has not assumed a parenting role.
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4. The Grandparents and Father agreed to the vacation of the prior Order of
July 25, 2000, consolidation of the two cases and entry of an Order in the form attached,
Ir {'-I-d 1
Date
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cq ine M, Verney, Esquire
Custody Conciliator
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JAMES R, LEHMAN and
SUEANN LEHMAN,
PLAINTIFF
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
: 01-2905 CIVIL ACTION LAW
JESSE J. LEHMAN and : IN CUSTODY
WHITNEY BLAIR MARIE PETTERSON,
DEFENDANT
PRAECIPE TO ENTER APPEARANCE
TO THE PROTHONOTARY:
Please enter the appearance ofthe Family Law Clinic on behalf of the Defendant, Jesse
Lehman, in the above-captioned matter.
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Alysia 1. Hudock
Certified Legal Intern
Date Y'17 1a-3
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ROBER E, RAINS
THOMAS M. PLACE
Supervising Attorney
ANNE MACDONALD-FOX
Staff Attorney
F AMIL Y LAW CLINIC
45 North Pitt Street
Carlisle, P A 17013
(717) 243-2968
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JAMES R, LEHMAN and
SUEANN LEHMAN,
PLAINTIFF
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
: 01-2905 CIVIL ACTION LAW
JESSE 1. LEHMAN and : IN CUSTODY
WHITNEY BLAIR MARIE PETTERSON,
DEFENDANT
CERTIFICATE OF SERVICE
I, Alysia 1. Hudock, hereby certifY that I am serving a true and correct copy of my
Praecipe to Enter Appearance on Paul Orr, counsel for Defendant, whose office is located at 50
East High Street, Carlisle, Cumberland County, Pennsylvania, and Marylou Matas of Griffie and
Associates, counsel for Plaintiff, whose office is located at 200 North Hanover Street, Carlisle,
Cumberland County, Pennsylvania, by facsimile and depositing a copy of the same in the United
States mail, postage prepaid, this!7....day of September, 2003,
Date
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Al a 1. Hudock
Certified Legal Intern
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THOMAS M, PLACE
Supervising Attorney
ANNE MACDONALD-FOX
Staff Attorney
F AMIL Y LAW CLINIC
45 North Pitt Street
Carlisle, P A 17013
(717) 243-2968
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SEP 1 8 2003 ~
JAMES R. LEHMAN and
SUEANN LEHMAN,
Plaintiffs
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
V.
: NO. 2001-2905 CIVIL TERM
JESSE J. LEHMAN and
WHITNEY B. M. PETTERSON,
Defendants
: CIVIL ACTION - LAW
: IN CUSTODY
ORDER OF COURT
AND NOW, this ?'Z- day of
consideration of the attached Custody ConciliatlO
follows:
, 2003, upon
Report, it is ordered and directed as
I, All prior Orders of Court, including the Order of Court dated July 7, 2003
are hereby vacated,
2, The paternal Grandparents, James R. Lehman and Sueann Lehman, the
Mother, Whitney B, M, Petterson, and the Father, Jesse 1. Lehman, shall have shared
legal custody of Kadin Darius Lehman, born November 28,1999, Each parent shall have
an equal right, to be exercised jointly with the other party, to make all major non-
emergency decisions affecting the Child's general well-being including, but not limited
to, all decisions regarding his health, education and religion,
3, The paternal Grandparents shall have primary physical custody of the
Child.
4, Father shall have periods of partial physical custody as agreed by the
paternal Grandparents and Father,
5, Mother shall have periods of partial physical custody as follows:
A. Beginning Friday, September 26, 2003, alternating weekends from
Friday at 6:00 p.m, to Sunday at 6:00 p.m,
B, Every Wednesday from 6:00 p,m, to 8:00 p.rn,
6, Thanksgiving shall be shared and alternated from 9:00 a.m, to 3:00 p,m,
and 3 :00 p,m, to 9:00 p,m, Grandparents shall have the earlier time in odd numbered
years and Mother shall have the earlier time in even numbered years,
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7. Christmas shall be divided into two Blocks, Block A shall run from
Christmas Eve at 12:00 noon to Christmas Day at 12:00 noon, Block B shall run from
Christrnas Day at 12:00 noon to December 26 at 12:00 noon, Mother shall have Block A
in odd numbered years and Block B in even numbered years, Paternal Grandparents shall
have Block A in even numbered years and Block B in odd numbered years.
8, Easter shall be shared and alternated from 9:00 a,m, to 3:00 p,m, and 3:00
p,m. to 9:00 p,m. Grandparents shall have the earlier time in even numbered years and
Mother shall have the earlier time in odd numbered years,
9, Mother shall be responsible for all transportation,
10. This Order is entered pursuant to a Custody Conciliation Conference, The
parties may modify the provisions of this Order by mutual consent. In the absence of
mutual consent, the terms of this Order shall control.
1.
cc: Paul Bradford Orr, Esquire, Counsel for Mother ~ ~
Alysia 1. Hudock, certified legal intern, Anne MacDonald-Fox, Es uire, Fibnily Law
Clinic, Counsel for Father
Marylou Matas, Esquire, Counsel for paternal Grandparents
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JAMES R. LEHMAN and
SUEANN LEHMAN,
Plaintiffs
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
V.
: 2001-2905 CIVIL TERM
JESSE J. LEHMAN and
WHITNEY B. M. PETTERSON,
Defendants
: CIVIL ACTION - LAW
: IN CUSTODY
PRIOR JUDGE: Edgar B. Bayley, J.
CUSTODY CONCILIATION SUMMARY REPORT
IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL
PROCEDURE 1915.3-8, the undersigned Custody Conciliator submits the following
report:
I. The pertinent information concerning the Child who is the subject of this
litigation is as follows:
NAME
DATE OF BIRTH CURRENTLY IN CUSTODY OF
Kadin Darius Lehman
November 28,1999 Paternal Grandparents
2. A Conciliation Conference was held in this matter on September 18,2003,
with the following individuals in attendance: the Mother, Whitney B, M. Petterson, with
her counsel, Paul Bradford Orr, Esquire. The Father, Jesse J. Lehman, Alysia 1. Hudock,
certified legal intern and Anne MacDonald-Fox, Esquire, Family Law Clinic, The
paternal Grandparents, James R, Lehman and Sueann Lehman, with their counsel,
Marylou Matas, Esquire,
3, The Honorable Edgar B. Bayley previously entered an Order of Court
dated July 7, 2003 granting sole legal custody to paternal grandparents, primary physical
custody to paternal grandparents with parents having periods of partial physical custody.
Father is currently incarcerated. Mother completed her phased in period of custody,
4,
q-{g-03
Date
The parties agreed to the entry of an Order in the form as attached.
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acq line M, Verney, Esquire
Custody Conciliator
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WHITNEY BLAIR MARIE PETTERSON, : IN THE COURT OF COMMON PLEAS OF
Petitioner : CUMBERLAND COUNTY, PENNSYLVANIA
v.
: CIVIL ACTION - LAW
: CUSTODYNISITATION
JAMES R. LEHMAN and
SUEANN LEHMAN and
JESSE J. LEHMAN,
Respondents
: NO. 2001-2905 CIVIL TERM
PRIOR JUDGE: Edgar B. Bayley
AFFlDA VIT OF SERVICE
COMMONWEALTH OF PENNSYLV ANlA
COUNTY OF CUMBERLAND
AND NOW, this 26th day of April, 2004, !, Paul Bradford Orr, attomey for Whitney Blair Marie
Petterson, Plaintiff, in the above-captioned action, hereby swear that! have served a true copy of the
Custody Complaint, executed by the Plaintiff in the above-captioned matter, upon the Defendant by
depositing the same in the U.S. Mail, postage prepaid, certified, return receipt requested. The original
return receipt card signed by Sue Ann Lehman on April 24, 2004 indicating service was effected, is marked
Exhibit "A", attached hereto and made a part hereof,
IA
Dated: 4(Lb fDf
By:
Paul Bradford Orr, Esquire
Attorney for Plaintiff
50 East High Street
Carlisle, PA ! 7013
(717) 258.8558
I.D. #71786
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WHITNEY BLAIR MARIE PETTERSON, : IN THE COURT OF COMMON PLEAS OF
Petitioner : CUMBERLAND COUNTY, PENNSYLVANIA
v.
: CIVIL ACTION - LAW
: CUSTODYNISITATION
JAMES R. LEHMAN and
SUEANN LEHMAN and
JESSE J. LEHMAN,
Respondents
: NO. 2001-2905 CIVIL TERM
PRIOR JUDGE: Edgar B. Bayley
PETITION FOR MODIFICATION OF CUSTODY
I, Petitioner, Whitney Blair Marie Petterson, resides at 2311 N, Front Street, Apt. 817
Harrisburg, Dauphin County, Pennsylvania 17110,
2, Respondents, James R. Lehman, SueAnn Lehman, resides at 273 Redwood Lane,
Carlisle, Cumberland County, Pennsylvania 17013,
3, Respondent, Jesse J. Lehman, resides at 919 Gibson Blvd., Harrisburg, PA 17104
4, Petitioner, Whitney Blair Marie Petterson is the natural mother of one (1) child,
namely, Kadin Darius Lehman, born November 28, 1999.
5. Respondents, James R. Lehman and SueAnn Lehman are the paternal grandparents of
one (I) child, namely, Kadin Darius Lehman, born November 28, 1999,
6, Respondent, Jesse J, Lehman is the natural father of one (I) child, namely, Kadin
Darius Lehman, born November 28,1999,
7, Pursuant to an Order of this Court dated September 22, 2003, a copy of which is
hereto attached as Exhibit A, it was Ordered that the natural Grandparents, James R. Lehman and
Sueann Lehman, the Mother, Whitney B.M, Petterson, and the Father, Jesse 1. Lehman, shall have
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shared legal custody of Kadin Darius Lehman, born November 28,1999, Natural Grandparents,
James R, Lehman and Sueann Lehman, shall have primary physical illstody of the minor child,
Kadin Darius Lehman with the natural father having period of partial physical custody as agreed by
the Grandparents and the Father, Mother shall have periods of partial physical custody alternating
weekends from Friday at 6:00 p,m, to Sunday at 6:00 p,m, and every Wednesday from 6:00 p,m, to
8:00 p,m,
8. Since the issuance of the above referenced Order, substantial circumstances and
facts have changed, giving rise to this Petition,
9, The best interest and welfare of the minor child, will be promoted by a
modification ofthe present custody agreement.
WHEREFORE, the Petitioner respectfully requests that this Honorable Court modifY the
current custody Order.
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Date:
,.
----
PAUL BRADFORD ORR, ESQUIRE
Attorney for Petitioner
50 East High Street
Carlisle, P A 17013
(717) 258-8558
Supreme Court ID# 71786
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VERIFICATION
I verify that I am the defendant and that the statements made in the foregoing
Petition for Modification of Custody are true and correct. I understand that false
statements herein are made subject to the penalties ofPa. C.S. S 4904, relating to unsworn
falsification to authorities.
DATE: L/ 14
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WIllTNEY BLAIR MARIE PETTERSON, : IN THE COURT OF COMMON PLEAS OF
Petitioner : CUMBERLAND COUNTY, PENNSYLVANIA
v.
: CIVIL ACTION - LAW
: CUSTODYNISITATION
JAMES R. LEHMAN and
SUEANN LEHMAN and
JESSE J. LEHMAN,
Respondents
: NO. 2001-2905 CIVIL TERM
PRIOR JUDGE: Edgar B. Bayley
CERTIFICATE OF SERVICE
I hereby certify that on this ~ay of, A ~R 1 L.
, 2004, I mailed a copy of
PETITION FOR MODIFICATION OF CUSTODY to the following persons at the following
address by D,S. Mail, Certified mail, postage prepaid, return receipt requested, delivered to
addressee only:
James R. Lehman
273 Redwood Lane t
Carlisle,PAI7013 )SftM p'a (,;
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Sueann Lehman ) f\
273 Redwood Lane
Carlisle, P A 17013
Jesse J. Lehman
919 Gibson Blvd,
Harrisburg, PA 17104
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Paul Bradford Orr, Esquire
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WIDTNEY BLAIR MARIE PETTERSON
PLAINTIFF
IN mE COURT OF COMMON PLEAS OF
CUMBERLAND COUN1Y, PENNSYL VANIA
v.
01-2905 CIVIL ACTION LAW
JAMES R, LEHMAN, SUEANN LEHMAN
AND JESSE J. LEHMAN
DEFENDANT
IN CUSTODY
ORDER OF COURT
AND NOW,
Tuesday, May 04, 2004
, upon consideration of the attached Complaint,
it is hereby directed that parties and their respective counsel appear before Jacqueline M. Verney, Esq. , the conciliator,
at 4th Floor, Cumherland County Courthouse, Carlisle on Tuesday, May 18, 2004 at 8:30 AM
for a Pre-Hearing Custody Conference, At such conference, an effort will be made to resolve the issues in dispute; or
if this cannot be accomplished, to define and narrow the issues to be heard by the court, and to enter into a temporary
order, All children age five or older may also be present at the conference, Failure to appear at the conference may
provide grounds for entry of a temporary or permanent order.
The court hereby directs the parties to furnish any and all existing Protection from Abuse orders,
Special Relief orders, a.nd Custody orders to the conciliator 48 hours prior to scheduled hea.ring.
FOR THE COURT.
By: Isl
Jacqueline M, Verntry. Esq.
Custody Conciliator
mhc
The Court of Common Pleas of Cumberland County is required by law to comply with the
Americans with Disabilites Act of 1990. For information about accessible facilities and reasonable
accommodations available to disabled individuals having business before the court, please contact our office.
All arrangements must be made at least 72 hours prior to any hearing or business before the court, You must
attend the scheduled conference or hearing,
;',
YOU SHOULD TAKE TIllS PAPER TO YOUR ATTORNEY AT ONCE, IF YOU DO NOT
HAVE AN ATTORNEY OR CANNOT AFFORD ONE, GO TO OR TELEPHONE mE OFFICE SET
FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP,
Cumberland County Bar Association
32 South Bedford Street
Carlisle, Pennsylvania 17013
Telephone (717) 249-3166
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WillTNEY BLAIR MARIE PETTERSON, : IN THE COURT OF COMMON PLEAS OF
Petitioner : CUMBERLAND COUNTY, PENNSYLVANIA
v.
: CIVIL ACTION - LAW
: CUSTODYNISITATION
JAMES R. LEHMAN and
SUEANN LEHMAN and
JESSE J. LEHMAN,
Respondents
: NO. 2001-2905 CIVIL TERM
PRIOR JUDGE: Edgar B. Bayley
AFFIDAVIT OF SERVICE
COMMONWEALTH OF PENNSYLVANIA )
COUNIY OF CUMBERLAND
AND NOW, this L~+laay of May, 2004, I, Whitney Blair Marie Petterson, Plaintiff, in the above-
captioned action, hereby swear that I have served a true copy of the Custody Complaint, executed by the
Plaintiff in the above-captioned matter, upon the Defendant, Jesse J. Lehman by hand delivery.
Dated
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JUN 0 8 2B04y;
JAMES R. LEHMAN and
SUEANN LEHMAN,
PlaintiffslRespondents
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
V.
: NO. 2001-2905 CIVIL TERM
JESSE J. LEHMAN
DerendantlR~pondent
And
WHITNEY B. M. PETTERSON,
Defendant/Petitioner
: CIVIL ACTION - LAW
: IN CUSTODY
ORDER OF COURT
AND NOW, this ----3- day of ~ C>~ , 2004, upon
consideration of the attached Custody Conciliation Report, it is ordered and directed as
follows:
I, The prior Order of Court dated September 22, 2003 shall remain in full
force and effect except as modified hereinafter:
2. Paragraph 5A shall be modified to provide that Mother's alternating
weekends shall be from Friday at 6:00 p,m, to Sunday at 8:00 p,m,
3, This Order is entered pursuant to a Custody Conciliation Conference. The
parties may modifY the provisions ofthis Order by mutual consent. In the absence of
mutual consent, the terms of this Order shall control. Another Conciliation Conference
may be scheduled by any party by contacting the conciliator and fue e arties,
1.
Edgar B, Bayley,
cc: Paul Bradford Orr, Esquire, for Mother
Jesse Lehman, pro se
919 Gibson Blvd.
Harrisburg, P A 17104
James R. Lehman and Sueann Lehman, pro se
273 Redwood Lane
Carlisle, P A 17013
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JAMES R. LEHMAN and
SUEANN LEHMAN,
PlaintiffslRespondents
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYL VANIA
V.
: 2001-2905 CIVIL TERM
JESSE J. LEHMAN,
DefendantlRespondent
And
WHITNEY B. M. PETTERSON,
Defendant/Petitioner
: CIVIL ACTION - LAW
: IN CUSTODY
PRIOR JUDGE: Edgar B. Bayley, J.
CUSTODY CONCILIATION SUMMARY REPORT
IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL
PROCEDURE 1915.3-8, the undersigned Custody Conciliator submits the following
report:
1. The pertinent information concerning the Child who is the subject of this
litigation is as follows:
NAME
DATE OF BIRTH CURRENTLY IN CUSTODY OF
Kadin Darius Lehman
November 28, 1999 Paternal Grandparents
2, A Conciliation Conference was held in this matter on June 8, 2004, with
the following individuals in attendance: the Mother, Whitney B, M, Petterson, with her
counsel, Paul Bradford Orr, Esquire. The Father, Jesse J, Lehman, pro se, The paternal
Grandmother, Sueann Lehman, pro se,
3, The Honorable Edgar B, Bayley entered an Order of Court dated
September 22, 2003 granting shared legal custody to mother, father and paternal
grandparents, primary physical custody to paternal grandparents with Father having
periods of partial physical custody as agreed by the parties and Mother having alternating
weekends and one evening per week. Mother filed a Petition to ModifY to obtain
additional time with her son, Mother expects to relocate to Cumberland County and
requests another conciliation conference once she has relocated. It is further expected
that Father's circumstances will change in October, 2004 and he may request another
conference also,
4, The parties agreed to the entry of an Order in the form as attached.
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JAMES R. LEHMAN and
SUEANN LEHMAN,
PlaintiffslRespondents
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYL VANIA
v.
: NO. 2001-2905 CIVIL TERM
JESSE J. LEHMAN,
Defendant/Respondent
AND
: CIVIL ACTION-LAW
WIDTNEY B.M. PETTERSEN,
DefendantIPetitioner
: IN CUSTODY
PRIOR JUDGE: Edgar B. Bayley
AFFIDAVIT OF SERVICE
COMMONWEALTH OF PENNSYLVANIA )
COUNTY OF CUMBERLAND
)
AND NOW, this 6th day of September, 2005, I, Paul Bradford Orr, attorney for Whitney Blair
Marie Pettersen, Defendant/Petitioner, in the above-captioned action, hereby swear that I have served a
true copy of the Petition for Modification of Custody, executed by the Defendant/Petitionerin the above-
captioned matter, upon the Respmdents by depositing the same in the V.S, Mail, postage prepaid,
certified, return receipt requested, The original return receipt card signed byJames R, Lehman on
September 2, 2005 indicating service was effected, is marked
, 't "A", attached hereto
BRA
ade a part
hereof.
Dated: September 6, 2005
By:
Paul Bradford Orr, Esquire
Attorney for Defendant/Petitioner
50 East High Street
Carlisle, PAl 70 13
(717) 258-8558
J.D. #71786
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JAMES R, LEHMAN AND SUEANN
LEHMAN
IN THE COURT OF COMMON PLEAS OF
PLAINTIFF
CUMBERLAND COUNTY, PENNSYLVANIA
v.
01-2905 CIVIL ACTION LAW
JESSE J. LEHMAN AND WHITNEY R.M,
PETTERSEN
DEFENDANT
IN CUSTODY
ORDER OF COURT
AND NOW,
Thursday, September 08, .2005
, upon consideration of the attached Complaint,
it is hereby directed that parties and their respective counsel appear before Jacqueliue M, Verney, Esq, ,the conciliator,
at 4th Floor, Cumberland County Courthouse, Carlisle on Thursday, October 06, 2005 at 10:30 AM
for a Pre-Hearing Custody Conference. At such conference, an effort will be made to resolve the issues in dispute; or
if this cannot be accomplished, to define and narrow the issues to be heard by the court, and to enter into a temporary
order. All children age five or older may also be present at the conference. Failure to appear at the conference may
provide grounds for entry of a temporary or pennanent order.
The court hereby directs the parties to furnish any and all existing Protection from Abuse orders,
Special Relief orders, and Custody orders to the conciliator 48 hours prior to scheduled hearing.
FOR THE COURT.
By: Isl
Tacqueline M. Verney. Esq. y
Custody Conciliator
The Court of Common Pleas of Cumberland County is required by law to comply with the Americans
with Disabilites Act of 1990, For information about accessible facilities and reasonable accommodations
available to disabled individuals having business before the court, please contact our office. All arrangements
must be made at least 72 hours prior to any hearing or business before the court, You must attend the scheduled
conference or hearing.
YOU SHOULD TAKE THIS PAPER TO YOUR ATTORNEY AT ONCE. IF YOU DO NOT
HA VE AN ATTORNEY OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET
FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP.
Cumberland County Bar Association
32 South Bedford Street
Carlisle, Pennsylvania 17013
Telephone (717) 249-3166
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}ECEIVED SEP 062005 O\}
JAMES R. LEHMAN and
SUEANN LEHMAN,
Plaintiffs/Respondents
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
: NO. 2001-2905 CIVIL TERM
JESSE J. LEHMAN,
Defendant/Respondent
AND
: CIVIL ACTION-LAW
WHITNEY B.M. PETTERSEN,
DefendantlPetitioner
: IN CUSTODY
PRIOR JUDGE: Edgar B. Bayley
ORDER OF COURT
AND NOW,
,2005, upon consideration ofthe attached Petition to Modify Custody,
it is hereby directed that the parties and their respective counsel appear before
, the
conciliator, at
on the_day of
,2005, at _ o'clock, _.m.,
for a Pre-Hearing Custody Conference. At such conference, an effort will be made to resolve the issues in dispute;
or if this cannot be accomplished, to define and narrow the issues to be heard by the Court, and to enter into a
temporary order. All children age five or older may also be present at the conference. Failure to appear at the
conference may provide grounds for entry of a temporary or permanent order.
FOR THE COURT:
By:
Custody Conciliator
The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with
Disabilities Act of 1990. For information about accessible facilities and reasonable accommodations available to
disabled individuals having business before the court, please contact our office. All arrangements must be made at
least 72 hours prior to any hearing or business before the court. You must attend the scheduled conference or
hearing.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT
HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE
OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP.
CUMBERLAND COUNTY BAR ASSOCIATION
2 LIBERTY AVENUE
CARLISLE, P A 17013
(717) 240-3166
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JAMES R. LEHMAN and
SUEANN LEHMAN,
Plaintiffs/Respondents
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
: NO. 2001-2905 CIVIL TERM
JESSE J. LEHMAN,
Defendant/Respondent
AND
: CIVIL ACTION-LAW
WHITNEY B.M. PETTERSEN,
DefendantIPetitioner
: IN CUSTODY
PRIOR JUDGE: Edgar B. Bayley
PETITION FOR MODIFICATION OF CUSTODY
I. Petitioner, Whitney Blair Marie Pettersen (Coleman), now resides with her husband,
Joseph Arthur Coleman, at 2906 Warren Way, Mechanicsburg, Silver Spring Township, Cumberland
County, Pennsylvania 17050.
2. Co-Respondents, James R. Lehman andSueAnn Lehman, reside at 273 Redwood
Lane, Carlisle, Cumberland County, Pennsylvania 17013.
3. Respondent, Jesse 1. Lehman, resides in the Shippensburg area, address unknown,
Shippensburg, Pennsylvania 17257. Co-Respondents are his parents however, and will accept
service on his behalf.
4. Petitioner, Whitney Blair Marie Pettersen (Coleman) is the natural mother of one (I)
child, named, Kadin Darius Lehman, born November 28,1999.
5. Co-Respondents, James R. Lehman and SueAnn Lehman are the paternal
grandparents of said child, Kadin Darius Lehman.
6. Co-Respondent, Jesse 1. Lehman is the natural father of the child, named, Kadin
Darius Lehman.
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7. Pursuant to prior Order's of Court dated July 7, 2003, September 22,2003, and June
9 2004 copies of which are attached hereto and marked as Petitioners Exhibit's A, B and C, it was
, , .
previously Ordered that the paternal Grandparents, James R. Lehman and SueAnn Lehman, and the
Mother, Whitney Blair Marie Pettersen (Coleman), and the natural Father, Jesse lLehman, shall
have shared legal custody of Kadin Darius Lehman. While paternal Grandparents were awarded
primary physical custody, Mother was awarded periods of Partial Physical Custody on alternating
weekends starting at 6:00 pm on Friday until 8:00 pm on Sunday and every Wednesday from 6:00
pm until 8:00 pm. Natural Father has no specified periods of Partial Custody per any prior Order of
Court.
8. Since the issuance of the above Orders, material and substantial circumstances and
facts have significantly changed and Petitioner is now requesting Primary Physical Custody of her
natural child, subject to periods of visitation for paternal Grandparents and avers the following:
A) Petitioner was married on July 24, 2004, to Joseph Arthur Coleman and
relocated to Cumberland County on December I, 2004;
B) Petitioner is now enrolled at Harrisburg Area Community College in a Dental
Hygienist Program. Additionally, her schedule is flexible and only requires approximately three (3)
hours per day, Monday thru Friday, to attend classes;
C) Petitioner and her husband have purchased a three (3) story townhouse with
three (3) bedrooms and three (3) bathrooms and a yard with settlement date to be in late September
2005;
D) Petitioner alleges that Paternal Grandparents continue to refer to rer as
"Whitney" to her son and also requires her son to address her as "Whitney" rather than mother. This
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has been discussed previously without success and Petitioner feels that son may be suffering from
"Parental Alienation Syndrome";
E) Petitioner recently learned that paternal Grandparents have a vacation
scheduled for September 23,2005 thru October 5, 2005, whereby paternal Grandmotherwas
planning on leaving child with a neighbor without informing Petitioner;
F) Petitioner alleges that paternal Grandparents leave the child with
neighbors/other relatives, "as she sees fit" on a regular basis, without notifYing the Petitioner,
although Petitioner would prefer to watch her own son over other individuals not known to her;
G) Petitioner alleges that paternal Grandmother smokes approximately two (2)
packs of cigarettes a day and paternal Grandfather smokes at least one (I) pack of cigarettes a day, all
in the presence of her son. Additionally, child has been required to empty ashtrays and has even, on
occasion, put unlit cigarettes in his mouth;
H) Petitioner alleges that the Mobile Home Park where in paternal Grandparents
resides has become an unsafe environment for her son; to wit: Mobile Home next door was the
subject of Arson whereby it is still under investigation and has not been removed from park; and a
variety of wild animals including but not limited to: rats; feral cats; raccoons; and skunks have been
observed on the premises;
I) Petitioner alleges that various crimes of a violent nature have occurred in the
Country Manor Mobile Home Park in recent months; to wit: attempted homicide; abduction of
children; assault on residents; etc.;
J) Petitioner alleges that paternal Grandparents refused to allow Petitioner the
right to Baptize her son at her family church and repeatedly state to her 8m that "god is not real" and
son is "made fun of' for saying prayers while in paternal Grandparents care;
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K) Petitioner alleges that while her son was attending Soccer Camp from July 18,
2005 thru July 22, 2005, paternal Grandmother provided the son with caffeinated ice tea only and
refused to allow mother to give the child water nor Gatorade. Further, it is alleged that he is
regularly given caffeinated drinks prior to bed time;
L) Petitioner alleges that in late 2004 paternal Grandmother agreed to enroll
Petitioner's son in Preschool Programs in order to get him acclimated to interacting with other
children but as soon as Petitioner gathered all pertinent information and registration forms paternal
Grandmother refused to allow her son to attend such a program;
M) Petitioner alleges that at kindergarten registration in August of 2005, paternal
grandmother incorrectly asserted to school authorities that Grandmother was "the Sole Legal
Guardian" (Order of Court dated 22 September, 2003, gave Shared Legal Custody of child to
paternal Grandparents and to natural Mother) of the child at question and thus, belittled and
minimized the status of natural Mother to School Officials;
N) Petitioner alleges that paternal Grandmother orders her not to cut child's hair
on a regular basis;
0) Petitioner alleges that natural Grandparents purchased a variety of"PG-13"
and "R" ,rated movies for her son to view, including but not limited to: "Alien v. Predator"; "Jurassic
Park"; "Jaws"; "The Boogie Man"; "Tremors", and regularly allows him to watch the TV show
"Lost".
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P) Petitioner alleges that her son has stated on repeated occasions that
"everything turns into monsters at night" no doubt due to the above referenced viewing of adult
movies and television;
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Q) Petitioner alleges that her son refuses to sleep in his own bed while in her
custody and further alleges that her five (5) year ten (10) month old son regularly sleeps in bed with
his paternal Grandparents;
R) Petitioner alleges that a caged German Shepard dog regularly stays in her
son's bedroom at paternal Grandparents mobile home;
S) Petitioner alleges that the only emergency exit from paternal Grandparents
mobile home is blocked with a chest style freezer, preventing any ability to quickly exit said Mobile
Home in the event of a fire.
9. Petitioner asserts that the best interests and mental, moral, and physical welfare of the
minor child will be enhanced by modifying the present Custody Agreement.
WHEREFORE, the Petitioner respectfully requests that this Honorable Court to modify the
current custody Order and provide her, as the natural Mother, Primary Physical Custody.
om, ~1lI0)
AUL BRADFO 0
Attorney for Petitioner
50 East High Street
Carlisle, P A 17013
(717) 258-8558
Supreme Court ID# 71786
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JAMES R. LEHMAN and
SUEANN LEHMAN,
Plaintiffs/Respondents
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
: NO. 2001-2905 CIVIL TERM
JESSE J. LEHMAN,
Defendant/Respondent
AND
: CIVIL ACTION-LAW
WmTNEY B.M. PETTERSON,
DefendantIPetitioner
: IN CUSTODY
PRIOR JUDGE: Edgar B. Bayley
CERTIFICATE OF SERVICE
I hereby certify that on this 31't day of, August, 2005, I mailed a copy of PETITION
FOR MODIFICATION OF CUSTODY to the following persons at the following address by
U.S. Mail, Certified mail, postage prepaid, return receipt requested, delivered to addressee only:
Mr. & Ms. James R. Lehman
273 Redwood Lane
Carlisle, P A 17013
Jesse J. Lehman
c/o James R. Lehman
273 Redwood Lane
Carlisle, PA 17013
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, RECEIVED OCT 0 7 ?nn~
JAMES R. LEHMAN and
SUEANN LEHMAN,
Plaintiffs/Respondents
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
V.
: NO. 2001-2905 CIVIL TERM
JESSE J. LEHMAN
Defendant/Respondent
And
WHITNEY B. M. PETTERSON,
DefendantlPetitioner
: CIVIL ACTION - LAW
: IN CUSTODY
ORDER OF COURT
AND NOW, this l7 day of ~V ~005, upon
consideration of the attached Custody ConciliatIOn Report, it is ordered and directed as
follows:
l. The prior Orders of Court dated July 7, 2003, September 22, 2003 and
June 9, 2004 shall be vacated.
2. Mother, Whitney B.M. Petterson shall have sole legal custody of Kadin
Darius Lehman, born November 28, 1999. In this regard however, Mother shall continue
to enroll the child in his current school placement for the 2005-2006 school year. Mother
shall also provide paternal Grandparents and Father with information concerning any
major decision concerning the child's general well-being as it relates to his education,
medical and religious decisions. Mother shall consult with, discuss and receive input
from paternal Grandparents and Father cOllcerning these matters.
3. Mother shall have primary physical custody of the child begiuning
Saturday, October 8, 2005 at 5:00 p.m.
4. Paternal Grandparents and Father shall have periods of partial physical
custody as follows:
A. Begiuning Friday, October 14, 2005 from after school to Monday
mornings at school time.
B. One evening per week as agreed by the parties.
C. Such other times as the parties agree.
5. Thanksgiving shall be shared and alternated such that Paternal
Grandparents and Father shall have physical custody ofthe child from 9:00 a.m. to 3:00
p.m. in odd numbered years and 3:00 p.m. to 9:00 p.m. in even numbered years and
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Mother shall have physical custody of the child from 9:00 a.m. to 3:00 p.m. in even
numbered years and 3:00 p.m. to 9:00 p.m. in odd numbered years.
6. Christmas shall be divided into two Blocks. Block A shall be from 12:00
noon on Christmas Eve to 12:00 noon on Christmas Day. Block B shall be from
Christmas Day at 12:00 noon to 12:00 noon on December 26. Mother shall have Block A
in odd numbered years and Block B in even numbered years. Paternal Grandparents and
Father shall have Block A in even numbered years and Block B in odd numbered years.
7. Easter shall be shared and alternated such that the Paternal Grandparents
and Father shall have physical custody from 9:00 a.m. to 3:00 p.m. in even numbered
years and 3 :00 p.m. to 9:00 p.m. in odd numbered years. Mother shall have physical
custody of the child 9:00 a.m. to 3:00 p.m. in odd numbered years and 3:00 p.m. to 9:00
p.m. in even numbered years.
8. Paternal Grandparents and Father shall be entitled to 4 weeks of physical
custody of the child in the summer, not more than 2 weeks consecutive, provided they
give Mother notice by January 1 of each year. Mother shall be entitled to 4 weeks of
physical custody ofthe child in the summer, not more than 2 weeks consecutive,
provided she give Paternal Grandparents and Fathernotice by January 1 of each year.
9. Maternal Grandfather shall not be alone with the child.
10. No party may say or do anything or permit another person to say or do
anything that may estrange the child from the other party, injure the opinion of the child
as to the other party, or hamper the free and natural development of the child's love and
respect for the other party.
11. Transportation shall be shared as agreed.
12. This Order is entered pursuant to a Custody Conciliation Conference. The
parties may modify the provisions of this Order by mutual consent. In the absence of
mutual consent, the terms of this Order shall control.
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Edgar B. Bayley,
cc: Maria Cognetti, Esquire, for Mother
Jesse Lehman, pro se
273 Redwood Lane
Carlisle, Pa 17013
James R. Lehman and Sueann Lehman, pro se
273 Redwood Lane
Carlisle, P A 17013
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JAMES R. LEHMAN and
SUEANN LEHMAN,
PlaintiffslRespondents
RECEIVED OCT 0 7 ion~
: IN THE COURT OF COMMON PLEAS OF f
: CUMBERLAND COUNTY, PENNSYLVANIA
V.
: 2001-2905 CIVIL TERM
JESSE J. LEHMAN,
DefendantlRespondent
And
WHITNEY B. M. PETTERSON,
DefendantJPetitioner
: CIVIL ACTION - LAW
: IN CUSTODY
PRIOR JUDGE: Edgar B. Bayley, J.
CUSTODY CONCILIATION SUMMARY REPORT
IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL
PROCEDURE 1915.3-8, the undersigned Custody Conciliator submits the following
report:
1. The pertinent information concerning the Child who is the subject of this
litigation is as follows:
NAME
DATE OF BIRTH CURRENTLY IN CUSTODY OF
Kadin Darius Lehman
November 28,1999 Paternal Grandparents
2. A Conciliation Conference was held in this matter on October 6, 2005,
with the following individuals in attendance: the Mother, Whitney B. M. Petterson, with
her counsel, Maria Cognetti, Esquire; the Father, Jesse J. Lehman, pro se and the paternal
Grandmother, Sueann Lehman, pro se.
3. The Honorable Edgar B. Bayley entered Orders of Court dated July 7,
2003, September 22, 2003 and June 9, 2004 granting shared legal custody to mother and
paternal grandparents, primary physical custody to paternal grandparents with Father
having periods of partial physical custody as agreed by the parties and Mother having
alternating weekends and one evening per week.
4.
The parties agreed to the entry of an Order in the form as attached.
~rnfEs~~~
Custody Conciliator
10- 7-06-
Date
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JAMES R. LEHMAN and
SUEANN LEHMAN,
PlaintiffslRespondents
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
: NO. 2001-2905 CIVIL TERM
v.
JESSE J. LEHMAN,
DefendantJRespondent
And
WHITNEY B.M. PETTERSON,
DefendantlPetitioner
: CIVIL ACTION - LAW
: IN CUSTODY
PRAECIPE FOR WITHDRAW AL/ENTRY OF APPEARANCE
TO THE PROTHONOTARY:
Kindly withdraw my appearance on behalf of Whitney B.M. Petterson, the
DefendantlPetitioner in the above-captioned matter.
Date: November 4, 2005
By:
ASSOCIATES
210 Grandview Avenue, Suite 102
Camp Hill, P A 17011
Telephone No. (717) 909-4060
Attorney for DefendantlPetitioner
TO THE PROTHONOTARY:
Kindly enter my appearance on behalf of Whitney B.M. Petterson, the
DefendantlPetitioner, in the above-captioned matter.
Date:\J4~3 \05
Whitney B. M.
Whitney B.M.
2906 Warren
Mechanicsburg, PA 17050
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